Speaker 1: This one, does CCO have any information on developing a compliance manual? What I did is take information from the manual that I have in my office and my daughter now oversees everything and it really came from the Office of the Inspector General because they have work plans. But there are seven components that provide a solid basis upon which a physician practice can create a voluntary compliance program, conducting internal monitoring and auditing, implementing compliance and practice standards, designating a compliance officer or contacts, conducting appropriate training and education, responding appropriately to detected offenses and develop a corrective action and develop open lines of communication with the employees and enforce disciplinary standards through well-publicized guidelines. And depending on the size of the practice, the physician does not have to implement all seven components of a full-scale compliance program. My compliance program is based more as a medical billing service and the OIG has their own plan, but honestly it's pretty much all the same. You want to provide a tool to strengthen the efforts of the providers to prevent and reduce improper conduct. When we start and we talk about the auditing and the monitoring, you want to choose an individual who will lead and involve other employees in carrying out procedures to ensure standards and procedures are current and complete. You want to focus on high-risk areas with the standards and procedures as well as claim submission audits. In other words, you want to make sure that the bills are accurately coded, that the services reflect documentation, services are reasonable and necessary, and ensure that there are no incentives for unnecessary services. I always divided the roles up. I used to oversee the whole office, but then I would delegate jobs, like this person is in charge of the aging and the follow-up to make sure everything was being done properly. This person would look at how the other billers were posting payments and how the explanation of benefits or remittance devices were coming in, were things getting written off when they should have been appealed, the information we get from the physician as well as how the biller would handle anything. If there's anything at all that is not right, then there should be protocol in place on how to handle it. You would establish practice standards and procedures. You want to select at least one individual to oversee the compliance plan. What we did is had a huge binder that had all the standard operating procedures in our office and a physician could do the same thing. Any insurance transmittals or bulletins, yes, we used to get them in the mail, but now everything is online. Anything that pertains to specialties or whatever, everything went into this book and everything was tabbed out in such a way. We also had forms called – I can't think of it now – it's like a report, an incident report. If you saw something whether it was internal or with a physician, you would write up an incident report and then you would give it to the person involved and they would come back with an answer. Depending on what it involved, it could involve the medical practice as well as your staff or it could just involve one-on-one, but you have to have things in place to say, well if this happens, then this is the end result. Our binder was pretty full with all the different standards and different forms for whatever. Then you need the written standards and procedures to identify the risk areas. Billing for items and services not provided or submitting claims for supplies and services that are not reasonable and necessary. Legal billing or billing for non-covered services as if covered. For example, one of the girls in my daughter's office has a doctor who just charged a patient $360 for some type of inserts for a shoe. The patient called Blue Cross Blue Shield, Federal Blue Cross Blue Shield and said, I just paid for this, doesn't my insurance cover it? Sure enough, they did. She came back and said, he's contracted with them and he shouldn't have taken my money, he should have billed insurance first. Well, it just happens that no Blue Shield plan paid for this except the Federal Blue Shield plan, so he had to give the money back. But if he didn't, we would have to take steps and tell him and we had to give instruction to the front desk and say, you have to check when you do this stuff and see what's covered and what's not. You just want to have those type of standards in place and depending on the practice that you're working for, you can devise it and customize it. You want to know about the misuse of provider ID numbers, that's huge. Don't ever put another provider number or put a provider down to provide a service because the other one hasn't been re-credentialed or something, I mean that's just like totally wrong. Don't unbundle codes or failure to properly use coding modifiers, up-coding, anything like that. If you see trends, you want to address it. When you designate a compliance officer or contacts, one person could be responsible for standards and procedures and the other one could be responsible for the periodic audits and ensuring the billing questions are answered. Actually it really does help and billers should like look if there's more than one biller in the department, look at each other's work and make sure things are not being overseen. As far as conducting appropriate training and education, that's a no-brainer. You determine who needs training in billing and coding, even front desk operations if they're not doing their job. Determine the type of training, seminars, in-service training, self-study, online courses such as what CCO offers. As far as responding to detected offenses and developing corrective action initiatives, when a practice detects a possible violation, the next step is to develop a corrective action plan such as steps involving the return of overpayments. Don't hold on to them. I have a doctor that owes like $1,000 and my daughter came up to me and said to me one day, what do I do? I give him this and he doesn't do anything with it and I'm still guiding her because she's managing the practice now and I just said, you have to tell him that he's breaking the law and if he doesn't, he's going to get in trouble. I told her different things to do and she wrote up an incident report and now she's meeting with him next week to go over everything because his front desk is collecting for copayments on procedures and no office visits. They come in for a procedure and there's no copayment charge. You also want to change the compliance procedures to prevent recurring problems. All the problems that involve employee misconduct, decide whether you're going to retrain, discipline, suspend or terminate. You want to keep the lines of communication open. Use a friendly process, if it's a huge group practice, you might have an anonymous box if you want to do something like that, but sometimes provisions stating failure to report a violation is in fact a violation of the compliance program, but use a simple and readily accessible procedure to process reports or erroneous or fraudulent conduct. The OIG recognizes anonymity may not be feasible, but employees need to know whom to turn to for assistance without fear of retribution. If you're going and asking someone for help that you're doing something wrong or you see someone else doing something wrong and you want to resolve it, that's a positive action. If it means that you've done something wrong or the doctor has and he's willing to cooperate, give the money back to the insurance company. If you coded incorrectly or took money when you shouldn't have, as long as it has a positive ending and you have something in place and it's just covering everything and keep everything in writing, then you're following the plan. As far as enforcing the disciplinary standards through well-publicized guidelines, the employees have to understand the consequences if they behave in a non-compliant manner. Disciplinary procedures and credibility and integrity to the compliance program is essential and they have to follow the rules. The disciplinary action should be flexible enough to account for all circumstances. As any employer, whether it's the doctor or someone that owns a billing company or whatever, you have oral warnings, written reprimand, probation, demotion, temporary suspension, termination, restitution of damages, and even go as far as referral for criminal prosecution. Most of the time, if you have your oral warnings and your written reprimands, you just want to make sure you keep a log of everything that you do because, like I said, when I was witness to a fraudulent act and a whistleblower, I had everything in place based on what the OIG plan was for my office and it really helped me. It saved me because I don't know what I would have done if I didn't have the proof that I terminated and that I tried to get the provider to act ethically. It's really the biller or the employee is implicated just as much as the physician or whoever is in charge, so you want to work as a team and maintain your log of all incidences no matter how minor they appear and maintain a paper trail because you never know when the Health and Human Services and the Department of Justice will knock on your door. Basically that's it. With this website, if you click on to it, I'm not manning this, but when you click on to it, it actually opens up to the website and it has all the points that I addressed, but there's so much information about the compliancy, provider education, all types of things that will help you so that you... Because I just touched on things, but there is so much more to it and you can pick and choose what would best suit your manual and then apply it. I worked with what I know I needed for my office, but for your medical practice, I definitely see how things operate and develop your manual for the practice.